Publication Plan November 2022

Object

Representation ID: 4899

Received: 23/12/2022

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The plan has not taken into account the need to promote sustainable patterns of development in altering Green Belt. Allocation of sites 463 and 284 would result in greater Green Belt harm than omission site 283. The plan fails to identify safeguarded land contrary to national policy. South Staffordshire is constrained by Green Belt and will continue to generate development needs. The previous plan identified at least 10 years' worth of safeguarded land. The Council should identify safeguarded land to meet longer term development needs in all sustainable locations.

Site 283 should be allocated to ensure a sustainable pattern of development. A Green Belt Position Paper by ZLA indicates the site provides less of a contribution to the Green Belt than the wider land parcels it sits within. The site would be contained by surrounding landscape features and would have no additional effect on Green Belt openness.

The ZLA paper indicates the site is of lesser Green Belt harm and indicates how compensatory benefits could be provided. A separate Green Belt Addendum Paper indicates that Sites 463 and 284 would result in moderate Green Belt harm.

Object

Representation ID: 4901

Received: 23/12/2022

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The proposed settlement hierarchy has altered from the Core Strategy due to the Rural Services and Facilities Audit (RSFA) 2021. Hansen Scores only provide a current snapshot and does not take account of additional opportunities development can provide or improved public transport patronage or modal shift strategies. The weighting given to access to employment is too great.

The RSFA places too much weight on rail provision. Regular and frequent bus services are available to Wolverhampton, Stourbridge and Merryhill. These serve a much wider catchment than rail for day to day needs and the ability to improve local services is much greater than rail. No recognition is given to access to employment within the village by means other than public transport, such as Heathmill Road and Smestow Bridge Industrial Estates and the village centre. The RSFA does not recognise changing patterns of working, whereby more people are choosing to work from home either part or all of the time, meaning availability of services and facilities in close proximity to meet day to day needs becomes more important, such as doctors, shops and schools.

Wombourne has 11.5% of the District's population but is only providing 8% of total housing delivery. It should provide 11.5% of housing delivery. Wombourne residents are 11% of the district-wide commuters to Birmingham and 12% of the district's commuters to the whole HMA, suggesting it should provide 11% of the District's contribution to HMA unmet needs. It also has a higher proportion of 0-16 year olds relative to other areas.

The Southern Sub Area in the SHMA has a need of 2,391 dwellings but planned housing supply totals only 1,831 dwellings. Its housing affordability ratio is also higher than the District average. There has been very strong demand for the existing Bloor Homes development compared to other similar high value area developments. The Viability Study 2021 identifies market values in Locality 5 to be amongst the highest in the Plan area.

The spatial strategy should be revised to take account of the above factors. It is readily apparent on this basis that Wombourne should be considered a Tier 1 settlement and have further growth.

Object

Representation ID: 4902

Received: 23/12/2022

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The allocation of Sites 463 and 284 are not sound. The NPPF (para 175) requires plans to allocate land with the least environmental or amenity value. There would be significant landscape and visual harm from the sites as identified in the accompanying assessment by ZLA. This also identifies impacts to the Wombourne Conservation Area. Release of the land is considered more detrimental to Green Belt purposes than Site 283 due to the accompanying ZLA assessments. The plan does not address whether the highways works to deliver the site are feasible and deliverable or their affect on viability. Site 283 would require no additional highway works to Bridgnorth Road and it performs better than other proposed allocations around Wombourne.

Object

Representation ID: 4903

Received: 23/12/2022

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The key determinant for Site 283 causing major negative landscape impacts is due to Green belt harm, based upon the findings relating only to the moderate-high harm area identified to the east of the site (which is disputed). It is not appropriate for the Green Belt Study to be used in the Sustainability Appraisal rather than the Landscape Sensitivity Assessment only, which would conclude differently. The Landscape Position Paper accompanying these representations considers this element of the SA to be flawed.